American Conference Institute ITAR Boot Camp

February 18-29, 2012
The Westin San Diego
San Diego, CA

Foreign Corrupt Practices Act, Maritime and International and Cross Border Transactions Partner Jonathan Epstein will speak at the American Conference Institute's 7th ITAR Boot Camp on the following panels:

"How to Comply with New Foreign, Dual and Third Country National Rules: Reconciling ITAR and Form I-129 Requirements with Foreign Anti-Discrimination and Privacy Law Restrictions." Topics will include:

  • how much you need to spend: Tailoring your compliance program to your company operations and industry risks
  • developing and updating your compliance manual, procedures and processes, including policy statements and message from senior management
  • integrating your Technology Control Plan (TCP) into your overall compliance program structuring your TCPs and TTCPs to meet ITAR requirements controlling foreign nationals’ access to ITAR controlled data: When a password, absolute lockdown and/or email controls are required
  • managing access risks posed by offshore IT support, cloud computing and e-rooms for electronic collaboration
  • protecting US-origin data on laptops and servers
  • managing email transfers of technical data: tracking and marking sensitive communications, and designating emails
  • protecting hardware and servers: when to create separate servers for controlled information and/or partition drives
  • incorporating foreign licensing and approvals into your daily compliance activities
  • creating an anonymous reporting tool and compliance hotline
  • scope and frequency of internal audits, and who should conduct them: Building a comprehensive self-assessment tool

"How Much an ITAR Violation Can Cost Your Company: Recent Cases to Mention in Your Business Case to Senior Management." Topics will include:

  • DDTC, DOJ, ICE and FBI approaches to ITAR enforcement
  • when a company and/or an individual can be held liable for ITAR violations
  • how fines/penalties are being applied by DDTC, and which violations have proven most costly
  • what can help to mitigate penalties
  • how export compliance programs should be structured to mitigate potential penalties
  • when a case can become criminal: When the Department of Justice will prosecute companies and individuals for ITAR violations, and the potential criminal penalties
  • criminal sentencing trends: Extent of potential jail time

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